A fact sheet on Dow's contamination of the Tittabawassee River and floodplain with
dioxin as published on the Resources page of the Justice for Bhopal, a student group at
the University of Michigan. Click here for their website http://www.umich.edu/~bhopal/

Dow Chemical and Dioxin

Historical and ongoing production at Dows many manufacturing sites globally has
and continues to result in the creation and release of dioxins to the environment.
Dows products, not only during manufacture, but also during use and disposal, can
also create and disperse dioxin. Operations at Dows global headquarters in Midland
Michigan have contaminated the Dow site and the city of Midland with dioxin. Highly
elevated levels of dioxin have also been found in the floodplain downriver from Dows
site and throughout the watershed -- in soils, sediments and wildlife. This legacy of
contamination and ongoing releases could represent a significant liability for Dow
Chemical. The material included below summarizes several agency and NGO reports on this
topic.

Dow has engaged in dioxin-generating activities for more than 60 years

has engaged in dioxin-

Dow has manufacturing facilities in dozens of countries, making products related
to food, transportation, health and medicine, personal and home care, and building
construction among others, and annual sales of $28 billion.

The company's 50,000 employees are engaged in research and development and production
of chemicals that include halogens, in particular chlorinated compounds, which can be
associated with the formation of dioxin and dioxin-like compounds in their manufacture and
disposal.

Over the years, Dow has manufactured a number of chemicals which can create dioxin as
an unintended byproduct, including mustard gas, Agent Orange, napalm, and pesticides like
2,4,5-trichlorophenol, 2,4-D, Dursban (chlorpyrifos), vinyl chloride monomer and ethylene
dichloride (monomers that are the building blocks of PVC or vinyl). Production of some of
these compounds continues at Dow facilities today. 2,4,D, for instance, is still
manufactured and used widely, and includes dioxin as a trace contaminant in the product
and the waste stream.

According to a Greenpeace report, Dow is:

The world's largest producer of chlorine and chlorine-based products.

 The largest producers of chlorinated pesticides in the US.

 The world's largest producer of the feedstocks that are used to make PVC
plastic.

 The nation's largest producer of chlorinated solvents.

As a result of these activities, additional sites of environmental contamination at
Dows manufacturing facilities globally are a possibility. In addition, combustion of
these products at the end of their life can also create and disperse dioxin to the
environment. PVC products for instance, represent a larger reservoir of potential dioxin
precursors in areas where the predominant disposal method is incineration.

Operations at Dows Global Headquarters in Midland have released dioxin

Dow has operated a manufacturing facility on the shores of the Tittabawassee River
since 1897. Over the years, Dow has manufactured a number of chemicals which can create
dioxin as an unintended byproduct of production or which can create dioxin during
disposal, including mustard gas, Agent Orange, napalm, and pesticides like
2,4,5-trichlorophenol, 2,4-D, Dursban (chlorpyrifos). Production of some of these
compounds continues at Dow today. 2,4,D, for instance, is still manufactured and used
widely, and includes dioxin as a trace contaminant in the product and the waste
stream.

In addition, Dow has operated on-site incinerators for years. Dow is continually
generating a large chlorinated waste stream as a result of the wide array of chlorinated
compounds produced on site. When this waste stream is incinerated, it generates dioxin,
which Dow is permitted to release to the air. Over the years, dioxin released from the
incinerator has deposited in the community.

"Ambient air dispersion modeling and monitoring indicate that the northeastern
quadrant of the city of Midland has been impacted by emissions from the
incinerators." (ATSDR Petitioned Health Consultation, 2002, draft)

Dow is also permitted to discharge dioxin to the Tittabawassee River along with a long
list of other industrial chemicals. In addition, the Dow site includes uncontrolled
landfills containing dioxin-contaminated wastes; very large tertiary treatment ponds with
dioxin-contaminated sediments; and numerous other historical dioxin reservoirs.

The City of Midland, has elevated levels of dioxin

A number of studies have now been conducted on surficial soils and sediments in
Midland. Most recently, in 1986, 35 locations were sampled in schools, parks, community
use areas and at 15 sites at the Dow plant. These locations were selected as a follow-up
to studies conducted in the mid-80s that found elevated levels of dioxin in the
area. The 1986 results found that many of the samples, particularly those located directly
adjacent to and downwind from the Dow facility exceeded Michigans residential
soil cleanup criteria of 90 ppt. These include samples taken at local elementary
schools and parks. Community (although not residential) sampling results ranged from 6 ppt
to 602 ppt. The Dow site levels ranged from 16.5 to 8,840 ppt.

In 1998, as a followup to the 1996 study, Dow collected samples at the Dow Corporate
Center. The Corporate Center is downwind from the manufacturing complex and near
residential areas, and was therefore used as a surrogate for additional community testing.
Soil samples at four sites found levels ranging from .07 to 583 ppt, with the highest
value measured across the street from a residential area. The perimeter of the site was
tested, and levels ranged from 6 ppt to 2,663 ppt. The plant site values were between 170
and 17,030 ppt dioxin.

Dioxin contamination has been noted in the watershed for years

Numerous fish and wildlife studies have noted elevated levels of dioxin in ecosystems
downriver from the Dow facility. The Michigan Department of Community Health has issued
fish advisories for the Tittabawassee River below Midland based on detected levels of
dioxins and PCBs in fish. Restrictions are recommended for carp, catfish, white
bass, smallmouth bass and all other species. Similar advisories have been issued for
waterbodies downriver from the Tittabawassee including the Saginaw River. Saginaw Bay and
Lake Huron (recipients of both the Tittabawassee and Saginaw Rivers, both have restricted
consumption advisories because of dioxin levels in fish.

A number of studies of birds and other wildlife in the region have demonstrated
elevated levels of dioxin, and developmental and other effects as a result of that
exposure.

In addition, occasional sampling of sediments have detected dioxins. Significant floods
through the years, including a large watershed-wide flood in 1986 has washed contaminants
downriver.

The downriver floodplain is contaminated with dioxin

Remarkably high dioxin levels in the floodplain 22 miles down river from Dow were
recently discovered. After an initial high reading, follow up sampling to confirm the
finding was done. Of 36 samples taken in 5 locations, a high of 7,261 ppt was found. This
level is 80 times above the state residential cleanup standard of 90 ppt. The average of
the samples was 985 ppt. Approximately 3,000 households are located in the
floodplain.

The results of follow up sampling to determine the extent of the contamination, and the
pattern of dioxin deposition were released in June 2002. River sediments were tested both
upriver from the City of Midland and Dows Headquarters, as well as downriver.
Upriver, levels of dioxin were between 1 and 5 ppt. Downriver, sediment samples ranged
from 5 ppt to 2,000 ppt. Depositional zones for river sediment appeared to have higher
levels of dioxin.

Dioxin is a potent poison

There is near scientific unanimity that dioxin is a carcinogen and a potent immune,
hormone and reproductive system toxin. A massive review of the science, called the Dioxin
Reassessment, is now nearing completion after more than ten years and two rounds of
scientific review. That reports conclusions have just been confirmed by a General
Accounting Office review. The most important findings include:

 The risk of getting cancer from dioxin is 10 times higher than reported in 1994
for the most highly exposed. The EPA now considers TCDD, the most potent form of dioxin to
be "carcinogenic to humans."

 Some adverse effects may already be occurring in humans at average levels of
exposure (background levels). Subtle effects, such as an impact on learning ability,
thyroid and liver functions and increased susceptibility to infections have been seen in
children exposed to background levels of dioxin.

 Dioxin also has the potential to cause adverse impacts on human metabolism,
developmental and/or reproductive biology, and perhaps, other effects in the range of
current human exposures. The evidence for these effects comes from a "limited"
number of studies of men exposed to dioxin. In these studies, subtle changes in
biochemistry and physiology, glucose tolerance, and diabetes, were detected.

 At above average levels of human exposure, dioxin has been linked to
cardiovascular disease, hypertension, miscarriage and infant death, birth defects, fewer
male births to female and soft tissue sarcoma, chloracne, and other conditions.

 Data indicate that laboratory animals and humans respond similarly to dioxin.
Most scientists involved in the reassessment as authors have indicated that it is
reasonable to infer that a spectrum of non-cancer effects will occur in humans, even
though there is an absence of "better" human data. Animal studies have linked
dioxin to endometriosis, demasculinization, birth defects like cleft palate and
hypospadias, hydronephrosis, increased susceptibility to bacteria, viruses, parasites and
tumors and suppression of the T cells.

 Dioxins adverse effects seem to occur at the most basic cellular level. Dioxin
alters the way genes function, turning them on or off at the wrong times or for too short
or too long a time period.

 EPA states that "The lack of clear indication of disease in the general
population attributable to dioxin-like compounds should not be considered strong evidence
for no effects of exposure to dioxins. Rather a lack of clear indication of disease may be
the result of the inability of our current data and scientific tools to directly detect
effects at these levels of exposure."